Tuesday, July 27, 2010

The most threatening problem of Musi River pollution is from water soluble, non-volatile, fairly reactive and environmentally persistent Organic Halogen Compounds, (POPs), some of which exhibit properties of high toxicity, bioaccumulation or carcinogenicity. These have applications as chemical intermediates in manufacture of pharmaceuticals, fine chemicals, dyestuffs; paints etc.The discharges from the industrial units engaged in these activities, in & around Hyderabad, find their way into Musi River.

The monitoring of this group of compounds in industrial effluents is of paramount importance, but APPCB, ignoring this vital aspect, concentrates only on less significant parameters such as COD,,BOD, TDs etc.As there does not seem to be an effective treatment to remove these toxic pollutants, the Supreme Court directed segregation of waste stream containing these non-degradable pollutants at the very source of their generation ie at the industry itself, instead of sending it to CETP or discharging into drains or sewers. But unfortunately this very aspect is being ignored both by the Industry and APPCB and trying to dilute pollution & accountability and shift the problem.

CAG Report

The CAG, which reviewed the activities, programmes and policies relating to the control of water pollution during 1994-2000, in its report placed before the Assembly on 31-3-2001, stated that ground water in areas along Musi River contained high levels of pollution and endangered public health. The water samples collected from down stream of Musi and analyzed by private agencies, are also reported to have shown high levels of Lead, Chromium, Mercury and Arsenic in ground as well as surface waters.

EPTRI Report

It is estimated that about 350 MT of TDS load is being pumped into Musi every day, along with untreated & under treated industrial effluents being let out into the river. Because of predominant conditions of scant flows for most part of the year, the Musi River cannot provide even the minimum dilution required to keep the concentration levels within stipulated limits. The other point is the residues of toxic Heavy Metals and POPs, which are not being tracked, are finding their way along with the effluents.

The seriousness of pollution problems in the villages down stream of Musi, can be judged from the concentration of heavy metals like Lead, Cadmium, Nickel, Chromium, Zinc, Selenium etc recorded in sewage sludge and fodder grass grown in the sludge. The data is given in State of Environment Report for Hyderabad published by EPTRI in 1996.I t is also evident from discoloration of, brass vessels used in some of the villages along Musi River

Discharges from CETP Jeedimetla (JETL)

The TDS concentration levels of treated effluents (diluted) being discharged by JETL into Duplicate K-S Sewers connected to Ambarpet STP, are reported to be varying between 12,000 to 17,000, far in excess of the stipulated standards, ultimately finding their way into Musi River, as Amberpet STP can not remove TDS Load, except diluting the concentration levels.

The APPCB is trying to mislead the public by saying that industrial effluents being let into Musi River is not even one percent of total effluents being discharged into the river and their concentrations are well within the permissible levels at the point of discharge. But the fact of letting out about 350 tons of TDS containing toxic and non-degradable substances into Musi every day is being suppressed. Where does it all go? During non-flood period, all most all these substances are being absorbed into soil and ground water, within 10 to 40 Kms of Amberpet STP, where the effluents are being utilized for agriculture purposes and for filling fish tanks etc, having serious adverse impacts on ground water, crops, livestock and the life.

How else APPCB can explain the presence of Arsenic of 1.33 mg/L in ground water of Edulabad village in Ghatkesar Mandal of R.R.District and large scale fish kill in Enkiryal Cheruvu fed by Musi waters hardly 30 Kms from Hyderabad, in Bibinagar Mandal of Nallagonda District in the last week of November 2000? This is ample evidence of high toxicity of effluents already being discharged into Musi and further discharges from CETP Pattancheru will only make things worse in the villages downstream of the river.

Discharges from CETP Pattancheru (PETL)

The Minister of State for Environment & Forests, Govt. of India, is reported to have complimented APPCB &PETL for commissioning 18 KM pipeline for transferring PETL treated effluents to surface-water standards to Amberpet STP & discharging into Musi. He is also reported to have stated that this will minimize water pollution at Pattancheru.

The following remain unanswered regarding the performance of PETL & Pollution Loads:

a) The Swedish Environmental Scientist pointed out that the process of water treatment plant of PETL is outdated and the treated water, though free from suspended solids and clarified, is still contaminated. How is it ensured that the discharges from PETL into 18 km pipeline are free from traces of toxic pharmaceutical ingredients and conform to inland -surface water standards?

b) If the outlet standards, applicable for discharge into inland surface waters, are being met by PETL, why not the treated effluents from PETL, be utilized by the member industrial units in Pattancheru Area? What is the need to use the 18 Km pipeline, to convey treated effluents, suitable for discharge into inland surface waters, all the way to STP at Amberpet, incurring considerable recurring expenditure for pumping etc?

c) The very fact that commissioning of 18 KM pipeline will minimize water pollution at Pattancheru, as reported to have been stated by the Minister, does it amount to shifting the pollution problem from Nakka Vagu to Musi River, for diluting the pollution concentration levels (pollution load remains the same) and the accountability that too cleverly camouflaged in a pipeline?

d) How does 18 KM pipeline & STP Amberpet help to prevent the load of 11 most abundant active pharmaceutical substances discharged from PETL and accumulating down stream of Musi, which is not a perennial river?

e) As the waterborne drugs promote antibiotic-resistant germs, especially when they are mixed with bacteria in human sewage, how does STP Amberpet get over the problem?

Abatement of Total Pollution of Musi River ?

It is to be seen, how abatement of total pollution of Musi River is going to be achieved under NRCD Phase-II (Musi Revitalization Project), by just building additional STPs, Laying new Sewer lines etc incurring considerable expenditure, while continuing to permit untreated \ under treated toxic industrial effluents into the Sewer Lines ?

Monday, July 19, 2010

MoEF Press Release of 15-07-10It is surprising that MoEF Press Release of 15 th July, asking Regional Chief Conservator of Forests from Bangalore to carry out inspection of the power project site of NCC at Sompeta to ascertain the factual position, does not refer to NEAA Order of 14 th July quashing Environmental Clearance granted to the power project of NCC, which is of vital importance.

The Press Release emphasizes the fact that the EAC also got it confirmed that the project site is Non-CRZ` area. The main point in question is, whether the project site is within wetlands or not, on which the press release is conveniently silent, and not about CRZ.

NEAA InspectionThe National Environmentl Appelate Authority (NEAA) after inspection of the project site along with expert on wetlands, Dr.S.Kaul, Director, MoEF and the local Revenue Divisional Officer accompanied by his Surveyor, finds that Govt. land to an extent of 972.69 acres allotted to the power project of NCC, is a typical Wetland of great ecological importance and the Authority stated that they had no doubts with regard to this.

It was also stated by NEAA that the reports of various agencies, including that of Sub-Committee of Expert Apprisal Committee (EAC) were found misleading and EAC was also carried away by these reports and reversed its decision of 32 nd meeting held on 13-14, October 2008.

NEAA Order of 14-07-2010The NEAA in its Order of 14 th July in appeal No.1 of 2010, categorically pronounced its view, that Environmental Clearance (EC) accorded by MoEF, based on wrong information, is bad and accordingly quashed the EC granted to Power Plant of NCC by MoEF Order dated 9 th December 2009 .

The NEAA also directed that MoEF should undertake survey of all wetlands in Srikakulam district for their Ecological Sensitiveness, as soon as possible, and pending this no project should be cleared in such locations.

ApprehensionsWhile the reports of various agencies, including that of sub-committee of EAC, were found to be misleading and the E C granted by MoEF to power project of NCC was quashed by NEAA, what is the purpose of the inspection of the NCC Project site by RCCF Bangalore at this stage?

The proposed inspection of NCC Power Project site and a reappraisal by the EAC, is apprehend to be nothing but an attempt to reopen the issue already adjudicated by the NEAA, going against the very spirit of the quasi-judicial nature of the proceedings before the NEAA. The question of another appraisal by EAC therefore should not arise at all.

Appeal.It is requested that survey of all Wetlands in Srikakulam district for their Ecological Sensitiveness, as directed by NEAA, be undertaken by MoEF at the earliest within a given time frame by involving local communities, concerned citizens and organizations.

It is also requested that the Environmental Clearances granted, ignoring public opposition, for Power Projects at Bhavanapadu and Meghavaram, which are an integral part of ecologically sensitive Naupada Wetland system, be suspended and the projects proponents be directed not to go ahead with the implementation of the projects, untill the proposed survey of the Wetlands in Srikakulam district is completed and further orders on the subject, based on the outcome of the survey, are issued

Thursday, July 1, 2010

The object of Environmental Impact Assessment (EIA) is to give environment its due place in decision making process, by clearly evaluating the beneficial & adverse effect of a development activity on environment, including socio-economic, cultural and aesthetic concerns. Early identification and characterization of critical environmental impact allows the public and the government to form a view about environmental acceptability of the proposed development activity. The EIA is to ensure that economic impacts of the environmental problems created by economic development are not passed on- To Others, To Elsewhere and To the Future.

Nuclear Establishment

In India the Nuclear Establishment- Atomic Energy Commission (AEC), whose chairman is always the head of DAE, Department of Atomic Energy ( DAE ) and Other Associated Organizations- enjoys unique access to political authority and is protected from external oversight and is in a position to ensure decisions, in their favour in almost all cases.The Atomic Energy Regulatory Board (AERB) is a regulatory authority to oversee the nuclear projects from the point of view of public safety. However, DAE also exercises administrative & financial powers over AERB, which is to report to AEC and depend on the DAE for its technical staff. Therefore the functioning of AERBauthorizing & regulating radioactive discharges & radiation dose and nuclear safety and whose regulatory control starts from site selection of Nuclear Power Plant (NPP)to its decommissioning, can not be expected to be independent and impartial..

Public Apprehensions on EIA Process

There is already widespread concern about, the potential environmental impacts of the Nuclear Power Plants (NPPs) and the effectiveness of EIA process for Nuclear Facilities. The three main components of EIA Process are a) EIA Study b) Public Consultation and c) Expert Committee that oversees Environmental Clearance.

a)EIA Study: The Nuclear Establishment is tempted to regard EIA simply as a means of obtaining Environmental Clearance and hence there is tendency to make the environmental impacts of nuclear projects look more benign than they are. The EIA is prepared by consultants who are retained to work on behalf of and by implication act in the interests of their client proposing the project. In addition the consultants have to depend on DAE and associated organizations for data about baseline levels of radio nuclides and expected levels of radioactive discharges. This allows DAE to be completely in charge of determining the main impact of concern- environmental release of radioactive materials, which cannot be relied upon.

If the EIA is found to be faulty/deficient at the technical/ factual levels, th proponent should be required to go through public consultation process again with revised EIA or may even be rejected as per sub Para 8 (vi) of EIA Notification of 2006.

b)PublicConsultation.

The experience so far regarding Public Consultation suggests that public opinion and inputs, critical of the EIAs, not to mention the projects themselves , count for little in decision making about nuclear projects. At best, the approach that nuclear establishment has taken towards the role of the public can be characterized as dealing with public participation "as a procedural issue than one of value." The public hearings for nuclear projects have always been short and rushed affairs with insufficient time for all interested and concerned participants to seek information or clarifications. The questions raised are seldom answered satisfactorily by the project proponents. For the most part, the public has also not been made to feel welcome at the hearings & many public hearings have featured massive police force.

This has to drastically change in the case of nuclear facilities, both because of the unique characteristics of nuclear fuel cycle and because of the vast majority of the population in India has little understanding of radiation and its associated hazards. The nuclear establishment should make use of the public consultation process to improve its decision making and helping it set public fears at ease, instead of treating as a ritual to comply with the legal requirement to the barest minimum and avoid them whenever possible.

c)Expert Committee that oversees Environmental Clearance.

An agency, completely independent of nuclear establishment, should be set up perhaps under the administrative and financial control of Ministry of Environment & Forests or Ministry of Science & Technology or proposed autonomous National Environmental Protection Authority (NEPA), and tasked with developing expertise in measuring radiation levels as well as calculating likely radiation doses to various population groups living around various nuclear facilities. Likewise the AERB should be kept outside the administrative and financial purview of Atomic Energy Commission.

With these changes, the role of the personal from the Nuclear Establishment in the Expert Appraisal process can and should be minimized, if not altogether eliminated, progressively. As regulatory control of AERB, starts from site selection of Nuclear Power Plant (NPP) to its decommissioning, the regulatory control of MOEF, CPCB, SPCB, in respect of NPPs is limited once Environmental Clearance is accorded

Proposed Nuclear Power Parks

The Nuclear Power Corporation of India, is reported to have received clearance from Govt. of India, to createcoast based Nuclear Power Parks, each havingminimum of six reactors of 1,000 or 1,650 MW totaling about 10,000 MW. The likely location of Nuclear Parks- Andhra Pradesh (Kowada, Srikakulam Dt.), Gujarat (Chhayamithi Virdi), Maharashtra (Jaitapur), Tamil Nadu (Koodankulam) and West Bengal ( Haripur). The DAE put a target of 18 months ( in December 2009) for acquiring the land, pre-project activity and creating basic infrastructure at the site, with specific Site Clearance from the Atomic Energy Regulatory Board (AERB), the active support from the State Governments for the land acquisition and the fast-track Environmental Clearance from the Ministry of Environment and Forests (MOEF)

Nuclear Park at Kowada village in Srikakulam district

The site selection for Nuclear Power Parkby AERB is very elaborate and complex exercise, involving study of enormous amount of field data. The land acquisition for Kowada NPP, if already started, without the prior site clearance by AERB is irregular. The creation of basic infrastructure at the site without prior Environmental Clearance of MOEF, will be violation of the provisions of Para 6 of EIA Notification of 2006, which stipulates that an application seeking prior environmental clearance shall be made after the identification of prospective site(s),, before commencing any construction activity, or preparation of land, at the site by the applicant.

Zoning around NPP

In order to ensure that, in the event of radioactivity releases from NPP, general public and environment are not adversely affected, the area around NPP is classified into the following zones:

a)Exclusive Zone: Up to 1.5 KM around the NPP is fenced area called Exclusive Zone and is under total control of the plant.

b)Sterilized Zone: Up to 5.0 KM around the NPP is a restricted area called Sterilized Zone. No new activity is permitted in this area. Existing activities, people, structures continue to remain.

c)Emergency Planning Zone: Up to 16.0 KM around the NPP is called Emergency Planning zone , where usually Township, Environmental Monitoring Lab (EML) Schools, Hospitals etc are located

d)Impact Assessment Zone : Up to 30.0 Km around the NPP is called Impact Assessment Zone normally monitored by EML

The Environmental Monitoring Lab (EML) should go into operation at least 2 to 3 years before NPP goes into operation and collect monitoring data on Air, Water, Soil, Food and Biological samples for background radiation, conventional pollutants etc and on site meteorological data. This lab is expected to continue measurements for a stipulated period even after decommissioning of NPP. (Working life 50-60 yrs)

Likely Hazards from Nuclear Power Plants

The main health hazard & environmental impact of Nuclear Power Plant could be due to radioactive discharges into Air and Water. The limits for radiation discharges and radiation dose are authorized and regulated by AERB, to ensure safety of site personal, Population living around NPP, Flora and Fauna.

Radiation Dosage

No dose of radiation is safe and all radiation is cumulative and each dose received ads to the risk of developing cancer or mutating genes in the reproductive cells. We are exposed to a background radiation dose of about 100 millirems per year from the Earth and the Sun. It has been estimated that if 125 people receive 100 millirems per year for 75 years, one of them will develop cancer. But the Nuclear Regulatory Commission (NRC), which is responsible for the oversight of the international Nuclear Power Industry, has decided that it is acceptable for the public to receive an additional 100 millirems per year from man-made radiation created through creation of nuclear energy, doubling the cancer risk.

Emissions from NPPs

Contrary to the nuclear industry claims, smoothly running NPPs are also not emission free. Even as per regulations stipulated, NPPs are estimated to routinely emit hundreds of thousands of Curies of radioactive gases and other radioactive elements into environment every year.

The water that cools the reactor core (primary coolant) becomes heavily contaminated with Tritium (radioactive hydrogen) and with Carbon 14, the long term medical and ecological effects of which do not seem to be well understood. The radioactive life of Tritium is estimated to be more than 200 years and that of Carbon 14 is 114,600 years.

A sustainable nuclear energy system would nesecciate a closed loop of Tritium & Carbon 14, such that they never enter ecosphere. At present their disposal is questionable, as they are routinely discharged into Seas, Rivers or Lakes. The primary coolant is not supposed to mix with the secondary coolant, but it normally does, allowing radiation to be released to the environment from the secondary coolant

Hazardous Nature of Nuclear Park

A regular 1,000 MW NPP contains an amount of long-lived radiation equivalent to that released by the explosion of 1,000 Hiroshima size bombs, which inevitably entails the release of radioactive materials into the environment. Can imagine the magnitude of routine and accidental radioactive releases at the proposed 10,000 MW Nuclear Park at Kowada in Srikakulam district, contaminating water and food chains and expose humans and animals now and for generations to come ?. Accidents such as Three Mile Island and Chernobyl condemn thousands of people, if not Lakhs, to pay the cost of nuclear power with their own lives and health.

In addition, the Nuclear Fuel Reprocessing Plants and Nuclear Waste Management Plants will have to be located in the vicinity of Nuclear Park. Each regular 1,000 MW NPP generates 30 tons of extremely potent radioactive waste annually, which remains radioactive for tens of thousands of years. This deadly waste material gets accumulated in huge cooling pools or in dry storage casks at NPP Sites. There is every danger ofthis unconfined wastes leaching, leaking, and seeping through soils into aquifers, rivers, lakes, and seas, where it enters and concentrates in the food-chains of plants, fish, animals and humans. This is a legacy that will lead to epidemic of cancer, leukemia and genetic diseases in populations living near Nuclear Power Plants and Nuclear Waste Management Facilities for many generations to come.

US Experiences

. In USA, out of 104 nuclear power plants in operation, 27 are found to be leaking radioactive tritium into the local ground water sources. Once the ground water is thus contaminated, it is difficult to make it potable again. Radioactivity will also lead to genetic disorders & disabilities that extend over decades, as it happened in Three Mile Island in USA, Chernobyl in Russia and similar instances in Japan and other places.

When such accidents caused major concerns in developed countries like USA where regulation and enforcement are strict, to say that they are safe in India is a highly misleading statement meant to keep the Indian public in the dark. The dangers of radioactive contamination can be understood from the fact that a small quantity of radioactive Cobalt thrown out as scrap from a laboratory in Delhi University during the first quarter of 2010 led to loss of life and injury to scores of scrap dealers.

The likelihood of accidents is higher in the case of nuclear power plants based on light water reactors which, incidentally, are going to be the technology that is going to be deployed in most of the new nuclear power projects coming up in India, especially the one at Kowada.

Conclusion

We cannot even imagine the consequences of a Chernobyl type of accident at the proposed Nuclear Park at Kowada, in which Lakhs would perish, with radiation contamination of the entire food-chain, making a large part of the area out of bounds for ever. Should not the people of Kowada have a right even to be told, about the imminent dangers of the proposed Nuclear Park in their vicinity?

Historically disputes between Industry, Governments and Community are always Unequal and Unfair, because people who have been damaged by irresponsible industries, almost never have the expertise or funding to conduct their own studies. Governments invariably support this mindless damage in the name of GDP Growth, which is highly discriminative and not Inclusive

At this time, when our National and State Leadership is advocating Nuclear Power for Energy Security & Sustainable Development, it is important that the facts are made known to the public of Kowada area, if their lives and that of their future generations are to be sacrificed for the sakeof Nuclear Park ?

About Me

Born in 1929, graduated in Electrical Engineering from College of Engineering, Guindy, Chennai (Madras), India in 1952. Joined Indian Navy in 1953, awarded Visista Seva Medal (VSM) and prematurely retired in 1975, in the Rank of Captain.
After retirement engaged in Industrial activities for about 20 years.Since 1995, engaged in Social and Community activities highlighting the adverse social and environmental impacts of Development Activities being undertaken without proper appraisal evaluation and assessment. Also associated with propagation of Sustainable Development and Resource Conservation.